Justia California Supreme Court Opinion Summaries

In 1981, Appellant was convicted of murder and sentenced to death. The Supreme Court reversed the penalty verdict. At the penalty retrial, the jury again sentenced Appellant to death, but the trial court modified the sentence to life imprisonment without the possibility of parole. The case was again remanded. On remand, the judge denied the motion to modify the verdict. On appeal, the Supreme Court vacated the death judgment and remanded for another hearing on Appellant’s application to modify the verdict. On remand, the trial court granted Appellant’s request to represent himself but denied his application to modify the verdict. The court then reinstated the death judgment. The Supreme Court vacated the judgment and remanded for another hearing on the application for modification of the death penalty verdict. On remand, the judge denied Appellant’s application to modify the verdict. On appeal, the Supreme Court affirmed the death judgment, holding (1) the trial court did not err in granting Appellant’s request to represent himself; and (2) Appellant forfeited his second claim on appeal. View "People v. Burgener" on Justia Law

After a jury trial, Defendant was convicted of three counts of first degree murder, two counts of premeditated attempted murder, and other crimes. The jury returned death verdicts as to all three murders, and the trial court sentenced Defendant to death. During guilt phase deliberations, the trial court discharged a juror for refusing to deliberate. On appeal, Defendant argued that the court erred in dismissing the juror. The Supreme Court reversed the judgment in its entirety, holding (1) because there was not a “demonstrable reality” that there was good cause to discharge the juror, the court abused its discretion in removing the juror; and (2) the error was prejudicial and required reversal of the judgment. View "People v. Armstrong" on Justia Law

The City of Montebello filed a complaint against three of its former council members and a former city administrator for conflict of interest, seeking a declaration that Defendants violated Cal. Gov't Code 1090 by voting on a waste hauling contract in which Defendants held a financial interest. After the contract was voided in a separate action, Defendants moved to strike the City’s complaint under the anti-SLAPP statute. The trial court denied the motion to strike. The court of appeal affirmed. The Supreme Court reversed, holding (1) the statutory anti-SLAPP exemption for public enforcement actions did not apply in this case; but (2) the votes cast in favor of the contract were protected activity under section 425.16, and because the court of appeal did not reach the issue of whether the City could establish a likelihood of the lawsuit succeeding, the case must be remanded. View "City of Montebello v. Vasquez" on Justia Law

Defendant pleaded no contest to second degree burglary and having served a prior prison term for vehicle theft. Defendant was sentenced to probation on conditions including a year in jail and a condition that he not enter the premises or adjacent parking lot of any Home Depot store in California. The appellate court struck the challenged probation condition, concluding that the condition was unconstitutionally overbroad. The court also suggested that the condition violated Defendant’s constitutional right to travel. The Supreme Court reversed, holding (1) the probation condition at issue was reasonably related to Defendant’s crime and to preventing future criminality, rendering it permissible under state law; and (2) the condition did not implicate Defendant’s right to travel and thus was constitutionally permissible. View "People v. Moran" on Justia Law

California’s anti-SLAPP statute provides that a cause of action against a person arising from allegations of certain activity shall be subject to a special motion to strike unless the court determines there is a probability that the plaintiffs will prevail on the claim. At issue here was how a special motion to strike operates against a “mixed caused of action” that combines allegations of activity unprotected by the statute with allegations of protected activity. Plaintiff filed a second amended complaint pleading four causes of action against Defendant. Defendant filed an anti-SLAPP motion seeking to strike allegations within a certain cause of action. The trial court denied the motion without deciding whether the complaint contained allegations of protected activity, ruling that the motion applied to the complaint as a whole, not to isolated allegations. The court of appeal affirmed, concluding (1) an anti-SLAPP motion must be brought against a mixed cause of action in its entirety; and (2) Plaintiff established a probability of succeeding on claims based on allegations of activity not protected by the anti-SLAPP statute. The Supreme Court reversed, holding that the Legislature’s choice of the term “motion to strike” reflects the understanding that an anti-SLAPP motion may be used to attack parts of a count as pleaded. View "Baral v. Schnitt" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, first degree burglary, and first degree robbery. The jury was unable to reach a penalty verdict, and after the penalty phase was retried with a new jury, the trial court sentenced Defendant to death for the murder conviction and to 212 years to life on the remaining counts. The Supreme Court remanded the case to the trial court to recalculate the noncapital portion of Defendant’s sentence but affirmed the judgment in all other respects, holding (1) there was no prejudicial error in the trial court’s pretrial rulings; (2) the trial court erred in imposing consecutive sentences for certain sex crimes because they were committed against a single victim on a single occasion; and (3) no other prejudicial error occurred during the guilt phase and penalty phase of trial. View "People v. Jackson" on Justia Law

When Plaintiff was hired by Defendants, he signed multiple arbitration agreements as a condition of employment. Plaintiff later sued Defendant, alleging racial discrimination, harassment, and retaliation. The complaint sought to bring claims on behalf of a “class of current and former employees of color.” Defendants filed a motion to compel individual arbitration based on the arbitration agreements. The trial court granted the motion but struck the class allegations, concluding that the agreements did not permit class arbitration. The court of appeal reversed in part, ruling (1) the trial court erred in concluding that existing precedent compelled the court to determine whether class arbitration was available; and (2) the availability of class proceedings under an arbitration agreement is for an arbitrator to decide in the first instance. The Supreme Court affirmed, holding (1) there is no universal rule allocating the decision of whether an arbitration agreement permits or prohibits classwide arbitration to a court or an arbitrator, but rather, who decides is in the first instance a matter of agreement with the parties’ agreement subject to interpretation under state contract law; and (2) under state law, the arbitration agreement in this case allocates the decision to the arbitrator. View "Sandquist v. Lebo Automotive, Inc." on Justia Law

Defendant was charged with the unlawful taking of a vehicle and receiving stolen property. The complaint also contained a gang enhancement allegation under Cal. Penal Code 186.22(b) that exposed Defendant to up to an additional four years in prison. Defendant pleaded guilty to the charges, and the trial court accepted the defense invitation to dismiss the gang enhancement allegation under Cal. Penal Code 1385(a). The District Attorney appealed, arguing that, by enacting section 186.22(g), the Legislature intended to eliminate a trial court’s section 1385(a) discretion to dismiss or strike entirely a section 186.22(b) gang enhancement. Because the trial court failed to state its reasons for the gang enhancement dismissal, the Court of Appeal remanded the case to allow the trial court to do so, and otherwise affirmed the trial court’s judgment. The Supreme Court affirmed, holding (1) a trial court has the discretion under section 1385(a) to strike entirely a sentencing enhancement under section 186.22(b)(1) for a gang-related offense; and (2) because the trial court orally statement its reasons for dismissing the gang enhancement on the record, no remand was required. View "People v. Fuentes" on Justia Law

The California Department of Water Resources (Department) sought to conduct environmental and geological studies and testing on over 150 privately-owned parcels of property that the state, in the future, might seek to acquire. Proceeding through the procedure established by the California Eminent Domain Law relating to precondemnation entry and testing, the Department sought a court order granting it authority to enter the properties to undertake environmental and geological testing activities. The trial court authorized the Department to enter the private properties and conduct environmental activities but denied the Department’s request to conduct geological testing. The Court of Appeal affirmed the trial court’s denial of the Department’s proposed geological testing and reversed the trial court’s authorization of environmental testing, concluding that the procedure established by the precondemnation entry and testing statutes did not satisfy the demands of the California Constitution’s takings clause with regard to both the geological and environmental testing sought by the Department. The Supreme Court reversed, holding that, assuming, without deciding, that the environmental and geological activities amount to a taking or damaging of property, the procedure established by the precondemnation entry and testing statutes satisfies the requirements of the California takings clause when the procedure is reformed to comply with the jury trial requirement of that clause. View "Property Reserve, Inc. v. Superior Court" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first degree murder and one count of second degree murder with the personal use of a firearm, among other crimes. A mistrial was declared after the first penalty trial. After a second penalty trial, the jury fixed the penalty as death. The trial court sentenced Defendant to death. The Supreme Court affirmed the judgment in its entirety, holding that there was no prejudicial error during the guilt phase of trial or the penalty phase of trial, and Defendant’s challenges to California’s death penalty scheme were unavailing. View "People v. Simon" on Justia Law